Invite Education Privacy Policy for “My College Corner”
Effective Date: October 8, 2018

Invite Education, LLC (the “Company”) owns and operates the website (the “Website”) and versions of the site, including this co-branded and/or framed version of the site, that refer to this Website Privacy Policy in a link. This Website Privacy Policy is designed to inform you of the types of information we collect from users, how we use that information, and the circumstances under which we will share it with third parties.

This Website Privacy Policy applies only to this Website. It does not apply to your use of any other websites (whether or not operated by us), including any websites to which we provide links or websites of our business partners, or to any activities that are not online. This Privacy Policy pertains to information collected only directly through the Website and does not apply to personal information collected from offline resources and communications (for instance, if you send the Company a postal letter, an email or call the Company). This Privacy Policy does not apply when you leave the site to enter other third party web site, which are opened in separate windows.

Please note that in some instances we may utilize framing techniques, which make it appear that you are on our Website when you are actually on a third-party Web site. The privacy policy that governs the collection and use of the information will be present on those pages so you always know whose privacy practices govern the collection and use of the information that you submit.

If you accessed the Website through a web site of one of the Company’s business partners, such as a co-branded or framed version of the site, the Company may share your information with such business partner. Such party’s use of your information will be governed by its own privacy policy, which you should review.

Please note that some features and/or functions referenced may not be included on this Website and the portions of this Website Privacy Policy that pertain to those features or functions may not be applicable.

This Website Privacy Policy is effective as of the date listed above and applies to all Websites that link to this Policy. Even if you read and/or agreed to a prior privacy statement, you need to review this updated version. We reserve the right to revise this Policy at any time and at our discretion. If we decide to make a material change to our Website Privacy Policy, we will post those changes and make them accessible on the homepage of the Website, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

The Website is not structured to attract children under 13, and the Company does not intend to collect personally identifiable information from anyone we know to be under 13 years of age. If you are under 13, please do not use our Website. If we find out we have unknowingly collected personally identifiable information about a child under 13, we will take all reasonable measures to delete that information from our system as soon as possible.

The Company and/or our third-party advertising or technology vendors may collect Non-Personally Identifiable Information using various tracking technologies described in this privacy policy. Non-Personally Identifiable Information is anonymous and includes information such as IP address, web pages which have been viewed, search queries that have been submitted, education interests, date and time, domain type, and responses by a visitor to an advertisement and content delivered by us or a third party advertising or technology vendor. The Company and our business partners may use different types of technologies to collect this type of information, including cookies and web beacons (1×1 pixels). Additionally, when registering for the site or requesting education information from one of our business partners on the Website, we may collect additional non-personally identifiable information about the individual. Examples of the non-personally identifiable data that may be requested include gender, ethnicity, military status, education background, geographic location and other information. None of this information (collectively referred to as “non-personally identifiable information”), by itself, or together with other non-personally identifiable information, can by its nature be matched with a specific individual. We have no access or control of third party tracking technologies.

Personally Identifiable Information, as used in this Website Privacy Policy, means any information or set of information that can be used to trace or identify a specific individual, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual. Examples of personally identifiable data that may be requested include name, address and email address, and phone numbers (home, mobile, office, and/or fax numbers), income estimates, your adjusted gross income, and/or amount of savings. The Company generally collects this information on the Website to personalize content. Providing your personal information is always voluntary, and you can always choose not to provide your personal information by choosing not to use our Website. By providing your personal information, you acknowledge and consent to our use of such information in accordance with this Website Privacy Policy.

During the course of the visitor’s use of the Website, we automatically collect certain information on the Website through cookies, web beacons, log files, and other common Website data collection techniques and we receive information from third parties.
Website Cookies:The Website may place “cookies” on a visitor’s computer. Cookies are small text files. Our Cookies save anonymized data about individual visitors, allowing the Website to recognize information about a visitor and help deliver personalized content and other services and functions.
The Website uses both session cookies, which terminate when a user closes his browser, and persistent cookies, which remain on the user’s computer until they expire or are manually deleted.
The Website may also contain coding from our business and technology partners that generates third-party cookies. Third-party cookies allow our business and technology partners to store non-Personally Identifiable Information they can access when you visit this or other Websites.
Most browsers allow you to control cookies, including whether or not to accept them and provide the ability to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Blocking cookies may result in a lower quality experience for you while you are the Website.
Web Beacons (1×1 Pixels or GIFS): Our Website contains coding known as Web Beacons that use 1×1 pixel images to capture and transmit the online activity of users on our Website. These Web Beacons typically transmit information about form completions and other Website activities in order to measure advertising effectiveness or store analytics information. In addition, the Company may use Web Beacons in HTML-based emails. This allows us to evaluate the effectiveness of our email communications and our marketing campaigns by showing how many emails recipients have opened.
Log Files: Like most Websites, our servers utilize log files. Log files store information including Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. Log files are used to analyze trends, administer the Website, track users’ movement in the aggregate, and gather broad demographic information for aggregate use. We use log file information at times to help identify you as you browse and to gather broad technical and demographic information on who uses our Website.

In addition to the information automatically collected, we also collect information that you provide to us when you register for an account on our Website, request information about a particular school or educational program, or otherwise voluntarily provide information about yourself and/or your educational interests.

In addition to the uses listed in other sections of this Website Privacy Policy, the information you provide to the Company and automatically-Collected information (both Personally and Non-Personally Identifiable Information) is used and shared to provide a number of different functions and services on the Website and in coordination with our technology and business partners. This utilization includes, but is not limited to, the following:

· The Company may contact you for feedback on Website features and functionality and improving the content and layout of our Website via electronic delivery and/or postal mail.
· Statistical analysis of your behavior, demographics and interests.
· We may use your geography to provide you with localized services, such as matching you with local education providers for some of the matching services we provide (e.g., educational opportunities or products or services available locally).
· We may use your physical mailing address, email address, mobile phone number, or other phone number to provide you with certain information or updates (such as our email newsletters, text messages, and phone calls) if requested by you or matches you with participating education providers in areas where you have requested information.
· We may use the account information to manage your account, facilitate the use of certain features of our Website (e.g., personalized education recommendations, suggestions of content that may be of interest to you, and creation of your educational interest lists) and to send you information about our company, services and products or offers from our business partners.
· We may use information about your use of our Website, such as your searches or browsing history and the education requests or interests, to make recommendations or suggestions to you and to provide you with advertising that is more relevant and interesting for you.
· If you have requested information from a service provider (such as an educational institution), we may use information about you to match you with additional appropriate service providers in our system.
We use cookies in a number of ways to make your use of our services more useful. We create cookie files on your computer and use them, for example, to save information on your username, ZIP Code, Website preferences, preferred educational categories, and requested education opportunities. We do this so you can avoid re-entry of this information each time you visit our Website, and to display certain usage information that may be helpful for you, such as your recent searches and/or recently viewed items. Cookies also allow us to deliver content and advertisements specific to your interests. For example, we may use cookies to collect anonymous information about your use of our site and services (including your browsing history, the terms you searched, the schools you viewed, etc.) and your interaction with our advertisements that are served on the Website or other sites. We also may provide your anonymous use and browsing information to third parties to allow them to provide you with advertisements that are tailored to your interests. You may decline our cookies or our third-party partner cookies if your web browser software permits, although this may prevent you from accessing certain features on our Website.
In addition to the uses described above, we may use your personal information for any of the following:
· To contact you via postal mail, email, phone or text message regarding the status of your inquiries relating to services or products listed on our Website. or to recommend additional service providers.
· To contact you via postal mail, email, phone or text message regarding account status, changes to this Website Privacy Policy or other terms applicable to your use of the Website.
· To contact you via postal mail, email, phone or text message to confirm your education inquiry, to confirm, complete or update your registration information, or for any other business reason related to your use of our Website.
· To contact you via postal mail, email, phone or text message in response to a customer service question from you, or in relation to any issue arising in respect of the agreement between the Company and you, or to resolve or attempt to resolve a dispute between users or between the Company and you.
· To assist law enforcement or other governmental agencies investigating cases of possible illegal activities by third parties.
· To enforce or apply our Terms of Use or other agreements, and protect the rights, property or safety of our users or others.
· To improve the experience of using the Website, improve the Company’s products and services, improve marketing and promotion of our products and services, customize the Website’s content and layout, and generally improve the Website to meet your needs better.

We aggregate personal information into statistics about users, their usage of the Website, traffic patterns, and demographics. We may provide third parties with such statistics, but not in a way that would make that information personally identifiable.
The Company may occasionally use external service providers to facilitate, improve or outsource elements of our service or operation of the Website, including processing transactions, sending emails, and providing marketing assistance or analysis. We may provide your information to, or exchange your information with, these service providers for use in their provision of services to us, such as fraud protection, compliance monitoring or marketing analysis. These external service providers may have access to personal information needed to perform their functions or services to us, but may not use it for other purposes including their own marketing.

As we continue to develop our business, we might buy or sell companies, subsidiaries or business units. In such transactions, user information is generally one of the transferred assets but remains subject to the promises made in any pre-existing Website Privacy Policy. In the event that we or substantially all of our assets are acquired, your information may be one of the transferred assets and we may share it with an actual or potential acquirer.

We may release information from or about you to cooperate with law enforcement officials and third parties to enforce all applicable laws, including but not limited to, laws relating to intellectual property rights, fraud, and other rights. We also may release information from or about you without a subpoena, court order or other substantially similar legal procedure to law enforcement entities or third parties when we believe release is necessary to comply with the law; to protect our rights, property, or the integrity of the Website, or the rights or property of our merchants/service providers, customers, users or third parties; or to prevent or investigate illegal activities, suspected fraud, situations involving potential threat to the physical safety of any person, or violation of our Terms of Use or other agreement between you and us. Further we can (and you authorize us to) disclose information from or about you to consumers who have alleged fraud or any other consumer dispute relating to their transactions and/or communications with you.

While the Company undertakes efforts to see that any third party with whom the Company shares personal or other information is under contractual obligation to use it solely for the purposes for which the information was disclosed and in accordance with the terms of this Privacy Policy, such parties are independent third parties over which the Company exercises no direct control. The Company is not responsible for, and will not be liable for, their conduct, actions, omissions, or information handling or dissemination practices.
The Company provides a number of different opportunities to review and change information in your profile or that we have stored about you. For example, you can go to the Website and log into your account to make desired changes. 

To request that information that had previously been voluntarily provided be removed from our database, send a request to the Company using the Company Contact Information below. We will attempt to delete such information, where feasible, after we receive a request from you. Notwithstanding any request from you, we may retain a record of your information that is necessary to comply with applicable law or as necessary to manage your account. 

Please be advised that by requesting that your data be removed from our database, you will be unsubscribed from our services. Also note that the information removal request does not carry forward and any subsequent return to the Website will result in additional information capture and sharing in accordance with this Privacy Policy.

The Website, as well as the electronic messages sent as part of the Company’s services, may contain links to other sites or services. The Company is not responsible for the privacy practices or the content of such third-party sites. If you have a question about the privacy policy of those other sites, please contact them directly.

By completing Website registration or otherwise providing your email address on one of our pages you consent that the Website may send email to you regarding our products and services or alerts of upcoming events. You can choose to opt out of receiving email communications from us by selecting to opt out by changing the settings in your account.
If we share your email address with our business partners, we no longer have direct control over the use of such information, and your rights regarding such use will be governed by our partner’s policies. You will have to contact them directly with any email opt-out request.

The Company has implemented technical, administrative, and physical security measures and other generally accepted industry standards designed to protect your information from unauthorized access and improper use. We review our security procedures on a regular basis to consider new or updated and appropriate technology and methods. Please be aware, however, that no method of transmission of information over the Internet, or method of electronic storage of information, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can send email us using the Company Contact Information.

California has passed legislation requiring certain disclosures be made available to California residents who use the Internet and provide information that may be used for marketing purposes. It requires any business that discloses a customer’s personal information to any third party for direct marketing purposes to provide the customer a method for obtaining the names, addresses and certain other specified details of anyone who might have received that personal information. If you are a California resident, you may request this information by requesting it using the Company Contact Information.

If you have any questions about this Website Privacy Policy, the practices of the Website, or your use of the Website, please contact us at:
Privacy Policy Administrator, Invite Education, 201 Washington St, Boston, MA 02108